Sixth Circuit affirms default False Claims Act judgment against pro se prisoner who abused litigation

by Ben Vernia | June 1st, 2010

In United States v. Goist, the Sixth Circuit Court of Appeals on May 20 upheld a default entry and judgment in favor of the government against a prisoner, Paul B. Goist. The government alleged that Goist violated the False Claims Act by filing “bogus Uniform Commercial Code liens, false Internal Revenue Service reports, and false involuntary bankruptcy petitions” against a district judge, a current and a former Assistant United States Attorney “in retaliation for their roles in his unarmed bank robbery conviction.”

The court found that the district court’s default judgment was proper because “Goist’s pro se filings [i.e., in response to the motion] were overwhelmingly unresponsive to the government’s claims,” and because “Goist failed to assert any meritorious defense to the government’s claims.”

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